CA Pest Control Recommendation Form

To: Paul Helliker <phelliker@cdpr.ca.gov>
Director, State of California, Department of Pesticide Regulation

While I was in California, I was given the CA Pest Control Recommendation Form; this form is the legal form that every pest control advisor in the State of California has to fill out before any pesticide can be used in an Agricultural Use category. You will note on the bottom where it says " all alternatives that would mitigate environmental problems have been considered". I maintain that most (if not virtually all) of your 5000 pest control advisors have not considered the use of ANY (much less ALL) alternatives. This neglect to name ANY alternatives and cavalier attitude has resulted in your "registered" POISONS continually CONTAMINATING the State's air and water, resulting in countless "registered" pesticide poisonings throughout the State. It is each Agricultural Commissioner's responsibility to audit PCA's records every 2 years and make sure they are actually recommending alternatives. I feel that every PCA should be audited and if they have not recommended any/all alternatives that "they" all be charged with perjury for recommending the same toxic "registered" pesticide POISONS year after year, after year because they are not considering ALL of the alternatives as your own law dictates and mandates. If you need help, I have field tested over 2300 safe and far more effective alternatives.
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Pest Control Recommendation
Operator of Property:

Location:

Method of Application:

Pest(s) To Be Controlled:

Name of Pesticide Rate/Acre/Unit Dilution Rate Volume/Acre or Unit

Schedule, Time, Conditions:

Surrounding Crop Hazards:

Proximity of Occupied Dwellings, People, Pets, Livestock:

Non-Pesticide Pest Control Warnings & Other Remarks:

Hazards and /or Restrictions:
    1. Highly Toxic to Bees:
    2. Toxic to Birds, Fish and Wildlife:
    3. Do not apply during irrigation or when run-off is likely to occur:
    4. Do not apply near desirable plants:
    5. Do not allow to drift onto humans, animals, desirable plants or property:
    6. Keep out of lakes, streams and ponds:
    7. Birds feeding on treated area may be killed:
    8. Do not apply when foliage is wet (dew, rain etc.):
    9. May cause allergic reaction to some people:
    10. This product is corrosive and reacts with certain materials (see label):
    11. Closed system required:
    12. Restricted use pesticide:
    13. Hazardous area involved:
    14. Other (See Attachment):

Crop and Site Restrictions:
    1. Worker entry interval: days
    2. Do not use within days of harvest
    3. Posting required: days.
    4. Do not irrigate for at least days after application.
    5. Do not apply more than more than applications /season.
    6. Do not feed treated foliage or straw to livestock:
    7. Plantback restrictions:
    8. Other (See Attachment) :

I certify that alternatives and mitigation measures that would substantially lessen any significant adverse impact on the environment have been considered and, if feasible, adopted.
Advisor license:
Employer:

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Well Mr. Helliker, we have just witnessed an outrageous act of terrorism on innocent and unsuspecting people in New York and Washington D.C. - we may have lost 5,000 people during that unprovoked attack. I would like to remind you that you consider it an "acceptable risk" to lose one, in every million, and we have over 50,000 "registered" POISONS; therefore, we lose many times that amount of innocent and unsuspecting victims every year to your "registered" POISONS. When will it be "legal" to use safe and far more effective (unregistered) alternatives to your "registered" POISONS?

Respectfully, Stephen L. Tvedten

Citeable Sections Pursuant to Food and Agricultural
Code Section 12999.5
California Code of Regulations, Title 3 (3CCR)

6426. Alternatives and Mitigation Measures.

(a) Each licensed agricultural pest control adviser and grower, when determining if and when to use a pesticide that requires a permit, shall consider, and if feasible, adopt any reasonable, effective and practical mitigation measure or use any feasible alternative which would substantially lessen any significant adverse impact on the environment.

(b) Each licensed agricultural pest control operator shall have available a copy of a written recommendation covering each agricultural use application of a pesticide that requires a permit, and operate in accordance with a pesticide permit issued by the commissioner. The standards for such recommendations are established in Section 6556.

NOTE: Authority cited: Sections 11456, 14005 and 14102, Food and Agricultural Code.

Reference: Sections 11501 and 14006, Food and Agricultural Code.
http://www.cdpr.ca.gov/docs/inhouse/calcode/020403.html#6426.0

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